Similar Documents at Byron |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20094D4401984-08-0606 August 1984 Request for Suppls to Util Amended Responses to Interrogatories 11 & 12.Certificate of Svc Encl.Related Correspondence ML20093G1391984-07-19019 July 1984 Answers to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20090C3051984-07-10010 July 1984 Answers to Intervenor Second Set of Interrogatories Re Reinsp Program.Certificate of Svc Encl.Related Correspondence ML20090C3571984-07-10010 July 1984 Third Set of Interrogatories Re Documents of Meetings & Contractor & Consultant Correspondence.Certificate of Svc Encl.Related Correspondence ML20092P2521984-06-28028 June 1984 Second Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20092N1771984-06-25025 June 1984 Response to First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20197H5221984-06-15015 June 1984 Second Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20197H6891984-06-14014 June 1984 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20091M2711984-06-0606 June 1984 Response to Applicant First Set of Interrogatories & First Request for Production of Documents.Certification of Svc Encl.Related Correspondence ML20090L1981984-05-18018 May 1984 First Request to Intervenors for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20090L2061984-05-18018 May 1984 First Set of Interrogatories to Intervenors,Requesting List of Witnesses to Be Presented on Intervenors Behalf at Reopened Hearings & Summary of Testimony.Certificate of Svc Encl.Related Correspondence ML20084K6751984-05-0909 May 1984 First Request to Comm Ed for Production of Documents Re Reinsp Program.Certificate of Svc Encl ML20084K4931984-05-0909 May 1984 First Set of Interrogatories to Comm Ed for Production of Documents Re Reinsp Program ML20079J3571982-12-22022 December 1982 Answers to NRC Second Set of Interrogatories Re Contention 1A.Certificate of Svc Encl.Related Correspondence ML20066J2511982-11-18018 November 1982 Page 16 of Util Response to Rockford League of Women Voters First Interrogatories & Request for Documents,Inadvertently Omitted ML20066J2631982-11-17017 November 1982 Response to First Set of Interrogatories & Requests for Documents.Certificate of Svc Encl ML20065R6911982-10-25025 October 1982 Answers to NRC Amended First Set of Interrogatories. Certificate of Svc Encl ML20065P9521982-10-22022 October 1982 Proposed First Set of Interrogatories.Proposed Motion for Production of Documents by NRC & Proof of Svc Encl ML20065M7281982-10-15015 October 1982 First Interrogatories & Request for Documents.Proof of Svc Encl.Related Correspondence ML20065M4781982-10-15015 October 1982 Reply to Amended First Request for Production of Documents. Proof of Svc Encl.Related Correspondence ML20065M4761982-10-15015 October 1982 Answers to First Set of Interrogatories,Pursuant to ASLB 821020 Memorandum & Order.Verification & Proof of Svc Encl. Related Correspondence ML20063N7511982-10-0505 October 1982 Answers to Amended Second Round of Interrogatories. Certificate of Svc Encl ML20069D5621982-09-10010 September 1982 Request for Info Re D4-D5 Model Steam Generators at Byron & Krsko Plants & for Documents.Related Correspondence ML20063M3371982-09-0303 September 1982 Amended Second Round of Interrogatories & Request for Production of Documents,Pursuant to 820818 Stipulation. Certificate of Svc Encl.Related Correspondence ML20062B0821982-07-30030 July 1982 Response to First Round of Interrogatories Re Financial Qualifications,Need for Power & Alternative Energy Sources ML20062B0671982-07-30030 July 1982 Response to First Request for Production of Documents Re Financial Qualifications,Need for Power & Alternative Energy Sources ML20054J5301982-06-24024 June 1982 First Set of Interrogatories,Originally Served on 800312. Proofs of Svc Encl.Related Correspondence ML20053D2641982-05-20020 May 1982 Interrogatories on SER & Supplemental SER to Be Answered by Util & Nrc.Certificate of Svc Encl.Related Correspondence ML20041E3851982-03-0202 March 1982 Supplemental Response to Util Request for Addl Info on Contention 8.Certificate of Svc Encl.Related Correspondence ML20049H8941982-02-24024 February 1982 Supplemental Response to Util Request for Addl Info Re Contention 2.Certificate of Svc Encl ML20040D5771982-01-21021 January 1982 Response to Util First Round of Interrogatories.Related Correspondence ML20010B1771981-08-0505 August 1981 Objections to Util First Round of Interrogatories. Interrogatories Are Premature & Not Presently Applicable. Certificate of Svc Encl.Related Correspondence ML20009B7031981-07-0808 July 1981 First Round of Interrogatories Directed to Dekalb Area Alliance for Responsible Energy & Sinnissippi Alliance for Environ.Certificate of Svc Encl.Related Correspondence ML20009B7041981-07-0808 July 1981 First Round of Interrogatories Directed to Rockford League of Women Voters.Certificate of Svc Encl.Related Correspondence ML19345G8761981-04-13013 April 1981 Response to Applicant Second Set of Interrogatories.Related Correspondence ML19309C7081980-03-12012 March 1980 First Set of Interrogatories.Includes Questions Re Intervenors' Revised Contentions & Deviations Occurring Since Issuance of Cp.Proof of Svc Encl ML19322E6331980-03-12012 March 1980 First Interrogatories Directed to Nrc.Includes Request for Specific Description of Deviation,Nonconformity or Change Occurring After CP Issuance.Proof of Svc Encl ML20039E6261980-01-0101 January 1980 Response to NRC First Request for Production of Documents. Related Correspondence 1984-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20149M2951996-11-29029 November 1996 Exemption from Requirements of 10CFR50.60 Re Safety Margins Recommended in ASME Boiler & Pressure Vessel Code Case N-514 TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20044A8111990-06-27027 June 1990 Comment Opposing Closure of Lpdr of Rockford Public Library ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20214X1871987-06-11011 June 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000 Based on Four Severity Level III Violations Noted During 860721-0808 Insp ML20205Q1711987-04-0202 April 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000. App Re Evaluations & Conclusions Encl IR 05000812/20100311987-02-26026 February 1987 Order Imposing Civil Monetary Penalty in Amount of $100,000 Based on Violations Noted During Insps on 850812-1031 ML20210T7321987-02-11011 February 1987 Unexecuted Amend 6 to Indemnity Agreement B-97 Substituting Item 3 of Attachment to Indemnity Agreement in Entirety W/ Listed License Numbers,Effective 870130 ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20213G4381986-10-24024 October 1986 Unexecuted Amend 5 to Indemnity Agreement B-97,substituting Item 3 of Attachment to Agreement in Entirety W/Listed License Numbers,Effective on 861106 ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 IR 05000506/20070221986-05-0202 May 1986 Order Imposing Civil Monetary Penalty in Amount of $25,000 for Violations Noted During Insp on 850506-0722.Violations Noted:Failure to Establish Radiological Safety Procedures & to Adequately Train Personnel ML20138C7301985-12-0909 December 1985 Order Imposing Civil Penalty in Amount of $25,000 Per 850606 Notice of Violation & Proposed Imposition of Civil Penalty.Licensee May Request Hearing within 30 Days of Date of Order ML20205E8741985-10-28028 October 1985 Exemption from GDC 4 of 10CFR50,App a Requirement to Install Protective Devices Associated W/Postulated Pipe Breaks Primary Coolant Sys.Topical Rept Evaluation Encl ML20102A2981985-01-0707 January 1985 Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant ML20099L2581984-11-27027 November 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20099G5381984-11-23023 November 1984 Supplemental Appeal Brief in Response to Intervenor 841106 Supplemental Brief on Appeal & in Support of ASLB 841016 Supplemental Initial Decision Authorizing Issuance of Ol. Certificate of Svc Encl ML20100K0411984-11-22022 November 1984 Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility ML20107H7841984-11-0606 November 1984 Supplemental Brief on Appeal of ASLB 841016 Supplemental Initial Decision Granting Authority for Issuance of Ol. Decision Should Be Reversed.Certificate of Svc Encl ML20140E4081984-10-31031 October 1984 Executed Amend 1 to Indemnity Agreement B-97,deleting Items 2A & 3 in Entirety ML20098G8841984-10-0202 October 1984 Joint Statement of RW Manz & W Faires Re Findings 3-11 Through 3-17 of NRC 830930 Integrated Design Insp Rept. Certificate of Svc Encl ML20098G8681984-10-0202 October 1984 Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied ML20098G8901984-10-0202 October 1984 Joint Statement of Kj Green & RW Hooks Re Integrated Design Insp ML20098G8911984-10-0202 October 1984 Joint Statement of Cw Dick & EM Hughes Re Independent Design Insp ML20098G8821984-10-0101 October 1984 Affidavit of Kj Green Re Integrated Design Insp Concerning Mechanical Engineering Work ML20098G8741984-10-0101 October 1984 Affidavit of Br Shelton Re Integrated Design Insp ML20098G8881984-09-29029 September 1984 Affidavit of RW Hooks Re Integrated Design Insp Concerning Structural Design ML20098G8831984-09-28028 September 1984 Affidavit of W Faires Re Findings 3-15 & 3-16 of NRC 830930 Integrated Design Insp Rept ML20098G8811984-09-28028 September 1984 Affidavit of Cw Dick Re Independent Design Review ML20098G8791984-09-28028 September 1984 Affidavit of RP Tuetken Re Readiness for Fuel Loading ML20098G8781984-09-28028 September 1984 Affidavit of RW Manz Concerning Findings 3-11 Through 3-14 & 3-17 of NRC 830930 Integrated Design Insp Re Westinghouse ML20098G8871984-09-28028 September 1984 Affidavit of EM Hughes Re Idvp ML20098G8851984-09-27027 September 1984 Affidavit of Rl Heumann Re Costs of Delay in Startup & Operation of Unit 1 ML20098E2371984-09-24024 September 1984 Reply to Intervenor 840918 Proposed Supplemental Initial Decision.Certificate of Svc Encl ML20097E7221984-09-13013 September 1984 Agreed Motion for Time Extension Until 841101 to File Petition for Hearing Re Emergency Planning Commitment W ML20097C5311984-09-12012 September 1984 Motion to Reopen Record to Include Plant Design as Issue. Supporting Documentation & Certificate of Svc Encl ML20097B7791984-09-10010 September 1984 Proposed Supplemental Initial Decision Re Reinsp Program. Certificate of Svc Encl ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6441984-08-28028 August 1984 Notice of Withdrawal of Appearance in Proceeding.Related Correspondence ML20112D5271984-08-24024 August 1984 Applicant Exhibit A-R-4,consisting of Feb 1984 Rept on Bryon QC Inspector Reinsp Program ML20112D5031984-08-24024 August 1984 Applicant Exhibit A-R-5,consisting of June 1984 Suppl to Rept on Bryon QC Inspector Reinsp Program ML20112D7441984-08-23023 August 1984 Intervenor Exhibit I-R-1,consisting of Undated List of Teutken Safety Category Insp Types ML20112D7511984-08-21021 August 1984 Staff Exhibit S-R-1,consisting of 840813 Instruction for Walkdown of Cable Tray Hanger Connection Welds ML20112D4641984-08-21021 August 1984 Intervenor Exhibit I-R-11,consisting of Undated Chronological Date Listing of Util Responses to Interrogatory 12.VA Judson to Mi Miller Re Interrogatory 12 & Supplemental Responses Encl 1999-03-02
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In the Matter of ) 03
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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454
) 50-455 (Byron Nuclear Power Station, )
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l COMMONWEALTH EDISON COMPANY S FIRST ROUND I LU Q OF INTERROGATORIES TO BE ANSWERED BY THE p JUL J g yggy
- I ROCKFORD LEAGUE OF WOMEN VOTERS u.s, % 0 Q,, mm% ae ;
'A d Pursuant to 10 CFR S 2.740b Commonwealth Edi El2TTh '
Company (Edison) requests the Rockford League of Woman Voters (League) to answer separately and fully in writing, under oath or affirmation, each of the following Interrogatories within 14 days of service.
INSTRUCTIONS AND DEFINITIONS
- 1. As used in these Interrogatories, whenever appropriate, the singular form of a word shall be interpreted as plural and the masculine gender shall be deemed to include the femini,ne.
- 2. As used in these Interrogatories, the term "and," as well as "or," shall be construed either disjunctively or conjunctively as necessary to bring within the scope of these Interrogatories any information which might otherwise
.be construed to be outside their scope. Dp3 3
- 3. As used in these Interrogatories, the term i[l
" person" incloces, without limiting the generality of its 8107170045 810708 PDR ADOCK 05000454 Q PDR
meaning, every natural person, corporate entity, partnership, association, governmental body or agency.
- 4. As used in these Interrogatories, the term
" identification" of a person or entity includes stating his, her, or its full name, his or her most recent home address and telephone number, his, her, or its most recent known business address and telephone number, his or her present position, snd his, her, or its connection or association with any party to this proceeding.
- 5. If any af the information contained ir. the answers to these Interrogatories is not within the personal knowledge of the person signing the Interrogatory, so state l
and identify each person, document and communication on which he relies for the information contained in answers not solely based on his personal knowledge.
- 6. If you cannot answer any portion of the following Interrogatories in full, after exercising diligerce to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portions.
- 7. If you claim privilege with respect to any irformation which is requested by these Interrogatories, specify the privilege claimed, the communication and/or answer as to which that claim is made, the parties to the communication, the topic discussed in the communication and the basis for your claim.
INTERROGATORIES
- 1. With respect to each Contention advanced by the League which has been admitted by the Atomic Safety and Licensing Board in the above-captioned proceeding, list the following:
- a. A concise statement of the facts supporting each Contention together with references to the specific sources and documents and portions thereof which have been or will be relied upon to establish suel, facts;
- b. the identity of each person expected to be called as a witness at the hearing;
- c. the subject matter on which the witness is expected to testify;
- d. the substance of the witness's testimony.
- 2. With respect to each witness identified in the League's response to Interrogatory 1 above, identify each document which the witness will rely upon in whole or in part in the preparation of his testimony or in the development of his position.
- 3. With respect to each witness identified in the League's response to Interrogatory 1 above, identify the witness's qualifications to testify on the subject matter on which the witness will testify.
4 Identify all persons who participated in the preparation of the answers, or any portion thereof, to these Interrogatories. r f) p'}
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Alan Paul Bielawski Paul M. Murphy, /
Suite 4200 / .
One First National Plaza / -
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Chicago, Illinois 60603 g ./ ~
312/558-7500
,/ / Alan Paul 'Bielawski Attorneys for Commonwealth Edison Company
. . _ . = . - - _- . . _ - . - . - -
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CERTIFICATE OF SERVICE i
The undersigned, one of the attorneys for the i
Commonwealth Edison Company, certifies that on this date he filed two copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory Commission and served a copy of same on each of the persons at the addresses shown on the attached service list by United States mail, postage prepaid.
1 i DATE: July 8, 1981 l *
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l' ' A! n P. 'Ifielawski
COMMONWEALTH EDISON COMPANY - Byron Station
, . Dockst Nom. 50-454 and 50-455 Marshall E. Miller, Esq., Chairman Dr. A. Dixon Callihan Atomic Safety and Licensing Board Union Carbide Corporation Panel P.O. Box Y U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Dr. Richard F. Cole Myron Karman, Esq.
Atomic Safety and Licensing Board Office of the Executive Legal Panel Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 Washington, D.C. 20555 Richard J. Goddard, Esq. Atomic Safety and Licensing Appeal Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 l
Atomic Safety and Licensing Board Secretary Panel Attn: Chief, Docketing and I U.S. Nuclear Regulatory Commission Service Section Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chief Hearing Counsel Ms.. Betty Johnson Office or the Executive Legal 1907 Stratford Lane Director Rockford, Illinois 61107 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dr. Bruce von Zellen Kenneth F. Levin, Esq.
Department of Biological Sciences Beatty, Levin, Holland, Basofir.
Northern Illinois University -
& Sarsany DeKalb, Illinois 60115 11 South LaSalle Street Suite 2200 Chicago, Illinois 60603 Dr. Axel Meyer Department of Physics Northern Illinois University DeKalb, Illinois 60115 Mr. Charles E. Morris l Executive Director l l Rockford Register Star l 99 East State Street
-Rockford, Illinois 61105 Ms. Beth L. Galbreath 734 Parkview '
Rockford, Illinois 61107 Myron M. Cherry', Esq.
Cherry, Flynn & Kanter One IBM Plaza Room 4501 Chicago, Illinois 60611
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